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Dear colleagues,

Join the proposals to the Standard on Civil.... and intercultural education, published below! They will be sent to the Ministry of Education and Science on September 7. Please anyone who wishes to become a co-submitter, send e-mail to amalipe.edu@gmail.com till 6 of September.

PROPOSALS

To the draft Regulations on civil, health, environmental and intercultural education

By civil society organizations, experts and teachers, working in the field of educational integration and intercultural education

NGOs working for educational integration of the Roma community were among the first who suggested the creation of a state educational standard for civic and intercultural education in 2010. We were involved in its development since 2012. We welcome the ambition of the Ministry of Education and Science the standard to come into force from the academic 2016/17!

At the same time we express our concern that the draft published for public comment omits some of the most important texts which had united a wide range of civil society organizations and experts in the field of intercultural education and educational integration. These texts were included in previous versions of the standard and their absence is now a concern that the standard will not create an appropriate basis for the implementation of the postulates of the Act on pre-school and school education, related to educational integration and the introduction of intercultural education.

Published draft standard contains two key gaps:

1. Chapter 3, "Implementing civil, health, environmental and intercultural education" does not contain any commitment on minimum mandatory parameters for implementation of CHEIE. The standard is very optional in this regard: it sets the possible ways to implement four types of education but does not set minimum requirements for the number of hours in preparation types and levels of education, which must be separated for CHEIE and each of its components. Thus CHEIE or any of its types (eg. Intercultural education) could be introduced very formally, through an insignificant number of hours and forms in some of the types of training. Thus, the targets would not be achieved (Chapter 2), as well as the set positive results (Chapter 4);

2. Chapter 5: "Institutional policies to support civic, health, environmental and intercultural education" does not contain requirements for the formation of institutional policies to create a favorable multicultural environment for the implementation of intercultural education. The problem with the lack of favorable multicultural environment is recognized by the National Assembly within the National Strategy of the Republic of Bulgaria for Roma Integration (2012) and the Ministry of Education through the Strategy for Educational Integration of Children and students from ethnic minorities (2004, 2010, 2015 years). Lack of favorable multicultural environment is clearly observed in the fact that about three quarters of Roma children are taught in a classroom with Roma students. Usually this leads to a very low quality of education and difficult socialization. As a result, many of these students drop out and the percentage of Roma young people who continue in secondary schools and universities is too low. At least four types of situations can be defined: rural schools with a predominant percentage of Roma students for objective demographic reasons (in most villages Bulgarian population is older and childless), schools in Roma neighborhoods in large cities (the so called "primary segregated schools"), schools in cities that were ethnically mixed, but today are "Roma" as Bulgarian parents have moved their children to another school and ethnically mixed schools which have classes with only Roma pupils ( "segregated classes").

The new education act explicitly forbits the fourth case through art. 99, para. 4 and art. 62, para. 4 and set guidelines for finding solutions to the remaining three situations. Unfortunately, the draft regulation does not create any prerequisites for the implementation of those postulates of APSE.

In addition, Annex 5 "Framework requirements for the organization of the lesson of  the class" highly underestimates the theme "Tolerance and Intercultural Dialogue": in primary and high school the only topic related to interculturality has only one hour a year. In the lower secondary level are provided two hours a year, which is also insufficient. All this, given that currently at least one third of the pupils are from ethnic minorities (according to expert estimates of the World Bank, UNDP) and Bulgaria is a member of the European family in which all nations are minorities and interculturality is the guiding principle.

Guided by the belief that gaps can and should be filled as a result of the procedure for public discussion, we propose:

1. Inclusion of separate article in Chapter 3, which sets a mandatory minimum of hours and forms for implementing CHEIE and its four components: on the types of training and levels of education.

We offer to the current text of the Regulation to be complemented

Art. 14. To implement the civil, health, environmental and intercultural education, the schools offer

• (1) In each of the classes in elementary, junior high and the first high school stages, the school organizes offering choices by students for advanced training of at least one of the subjects "Civic Education", "Health Education", "Environmental Education" or "Intercultural education "under the conditions of the state educational standard of the curriculum, so that every student has the opportunity to choose any of the subjects at least once in each stage

• (2) In each of the classes in elementary, junior high and the first high school stages, the school organizes offering a choice by students of optional hours of additional training in at least one of the modules of civic, health, environmental and intercultural education so that every student to be able to select each of the modules at least once in each stage

• (3) In each of the classes in primary and secondary school stages, the school organizes a school offering a choice by the students of classes on interests within day organization of the school day on civil, health, environmental and intercultural education

2. Inclusion of the requirements for the development of institutional policies to create a multicultural environment and overcoming the existing de facto segregation in Chapter 5

We offer the current text of the Regulation to be supplemented:

Art. 18. (1) An integral part of institutional policies, supporting civic, health, environmental and intercultural education is the creation of a multicultural environment

(2) The multicultural environment is a way of organizing educational environment that requires real and equal inclusion of participants (children and students, educational actors, parents) who have different cultures and equal interaction between them.

 (3) Practical creation of multicultural environment is realized through:

• 1. Non-admission of students from only one ethnoc group in forming a group or class to kindergartens and schools with multiethnic composition of children and students.

• 2. In the case of existing groups and classes that do not meet par. 2, the director of the kindergarten or school take measures for their transformation according to the requirements of par. 1 within one academic year

• 3. Developing and implementing policies to reduce to a maximum of four years in which a child or student from a place with multiethnic population to be trained in monoetnic educational environment;

• 4. In cases where students in compulsory education age in a given area are representatives of only one ethnic group, school principals and RAE undertake targeted measures to create intercultural school forms for joint activities for children and students of that village and other settlements

3. Increase the number of hours provided for tolerance and intercultural dialogue in Annex 5 "Framework requirements for the organization of the lesson of class" to a minimum of 4 hours per year in each class of the elementary, junior high and first high school stages.